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  • IESBA Proposes Change to Code of Ethics Definition of Those Charged with Governance

    New York, New York English

    The International Ethics Standards Board for Accountants (IESBA) today released for public exposure a proposed change to the definition of “those charged with governance” in the IESBA Code of Ethics for Professional Accountants (the Code).

    The objectives of the change are to more closely align the definition of “those charged with governance” in the Code with that in the IAASB’s International Standard on Auditing (ISA) 260, Communication with Those Charged with Governance, and to eliminate any confusion as to how it is defined. The IESBA is of the opinion that the proposals do not call for any change in systems or common practice, should they be approved.

    The change specifically aims to clarify that a subgroup, such as an audit committee, may assist the governing body in meeting its responsibilities. In those cases, the auditor shall determine with whom within the entity’s governance structure to communicate.

    “Through this Exposure Draft, the IESBA seeks to ascertain whether the proposed change to the definition adequately clarifies the term ‘those charged with governance.’ The IESBA believes this will contribute to more consistent application of the Code, which is critical to our mission to support the global adoption and implementation of the Code,” said Ken Dakdduk, chair of the IESBA.

    How to Comment
    The IESBA invites all stakeholders to comment on its proposals in the Exposure Draft, Proposed Change to the Definition of “Those Charged with Governance.” To submit a comment, visit the IESBA website at www.ethicsboard.org. Comments on the Exposure Draft are requested by October 31, 2012.

     

    About the IESBA
    The International Ethics Standards Board for Accountants (IESBA) is an independent standard-setting board that develops and issues, in the public interest, high-quality ethical standards and other pronouncements for professional accountants worldwide. Through its activities, the IESBA develops the Code of Ethics for Professional Accountants, which establishes ethical requirements for professional accountants. The structures and processes that support the operations of the IESBA are facilitated by IFAC. Please visit www.ethicsboard.org for more information.

    About IFAC
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

     

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  • SMP Quick Poll Reveals Accountants and Their Small Business Clients Share Similar Challenges

    New York, New York English

    Complexity and pace of change of regulations, in particular tax requirements, topped the list of challenges faced by small- and medium-sized accountancy practices (SMPs) and their small business clients in the first half of 2012, according to the SMP Quick Poll results released today by IFAC.

    Keeping up with new regulations and pressure to lower fees were the top two challenges for practitioners. Their clients face similar challenges, according to the SMPs polled, with burden of regulation topping the list and three economic factors—pressure to lower prices, economic uncertainty, and difficulties accessing finance—nearly tied as the next biggest challenges.

    “The results are critical to IFAC and its member bodies gaining a deeper understanding of the challenges and opportunities faced by SMPs globally,” said SMP Committee Chair Giancarlo Attolini. “We were very pleased with the high response rate to this survey, which is testimony to the fact that our member bodies, who heavily promoted the poll, are just as concerned about SMPs as we are.”

    The poll also included questions on business drivers and outlook. For nearly half the respondents, business from new clients is the main driver of growth by a wide margin with less than half as many respondents citing increased revenue from existing clients as their main driver of growth. However, when asked about performance expectations, the largest portion of practitioners expect no change in business in the current year compared with 2011.

    See the complete report including selected results broken down by size of practice and region in the IFAC SMP Quick Poll: May–June Results.

    The mid-year 2012 poll received 3,678 responses, 50% more than the last edition of the poll in December 2011. The poll, intended to take a snapshot of key challenges and trends influencing SMPs globally, was conducted in 15 languages from May 7 to June 14, 2012. IFAC wishes to thank the many member bodies and regional organizations that translated and/or helped promote the poll to their members.

    About the SMP Committee
    The SMP Committee of the International Federation of Accountants (IFAC) represents the interests of professional accountants operating in small- and medium-sized practices (SMPs). The committee develops guidance and tools and works to ensure the needs of the SMPs are considered by standard setters, regulators, and policy makers. The committee also speaks out on behalf of SMPs to raise awareness of their role and value, especially in supporting SMEs, and the importance of the small business sector overall.

    About IFAC
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.


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  • IPSASB Publishes Consultation Paper on 2013-2014 Work Program

    New York, New York English

    The International Public Sector Accounting Standards Board (IPSASB) today released for comment the Consultation Paper, Consultation on IPSASB Work Program 2013–2014. This is the first public consultation by the IPSASB on its work program. It signals the IPSASB’s intent to continue this practice and consult publicly on future work programs.

    This public consultation is limited to the work program for the period 20132014. This is because the IPSASB is currently in a period of significant activity and transition. The Public Sector Conceptual Framework project, the IPSASB’s highest priority project, is scheduled to be completed in 2014. In addition it is anticipated that public interest oversight and related governance changes for the IPSASB will be implemented in 20142015.

    "This first public consultation on the IPSASB’s work program for 20132014 will assist the IPSASB in creating a short-term work program that meets stakeholders’ needs. In fact we see this as a first step to a broader and even more fundamental public consultation of our broad strategic direction in the future," explained IPSASB Chair Andreas Bergmann.

    How to Comment
    To access the Consultation Paper or to submit a comment, please visit the IPSASB website at https://www.ifac.org/public-sector. Comments on the Consultation Paper are requested by October 31, 2012. The IPSASB encourages IFAC members, associates, and regional accountancy bodies to promote the availability of this Consultation Paper to their members and employees.

     

    About the IPSASB
    The IPSASB develops accounting standards and guidance for use by public sector entities. The structures and processes that support the operations of the IPSASB are facilitated by IFAC. The IPSASB receives support (both financial and in-kind) from the World Bank, the Asian Development Bank, and the governments of Canada, China, New Zealand, and Switzerland.

    About IFAC
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

     

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  • 2012 Editions of the Handbooks from IAASB, IESBA, and IPSASB

    New York, New York English

    The International Federation of Accountants (IFAC) today announced the availability of the 2012 editions of the handbooks from the International Auditing and Assurance Standards Board (IAASB), International Ethics Standards Board for Accountants (IESBA), and International Public Sector Accounting Standards Board (IPSASB).

    2012 Handbook of International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements
    The 2012 edition includes two new standards: ISAE 3410—Assurance Engagements on Greenhouse Gas Statements and ISAE 3420—Assurance Engagements to Report on the Compilation of Pro Forma Financial Information Included in a Prospectus. It also includes IAPN 1000—Special Considerations in Auditing Financial Instruments, and revised versions of the Preface, ISA 315—Identifying and Assessing the Risks of Material Misstatement through Understanding the Entity and Its Environment, ISA 610—Using the Work of Internal Auditors and conforming amendments to other ISAs as a result of this revision, and ISRS 4410—Engagements to Compile Financial Statements. It will be available in July and can be pre-ordered here.

    2012 Handbook of the Code of Ethics for Professional Accountants
    The 2012 edition includes a new introduction and editorial amendments. It will be available in July and can be pre-ordered here.

    2012 Handbook of International Public Sector Accounting Pronouncements
    The 2012 edition includes a new standard: IPSAS 32, Service Concession Arrangements: Grantor. IPSAS 32 is effective for annual financial statements covering periods beginning on or after January 1, 2014. The 2012 handbook also incorporates the amendments made as a result of the IPSASB’s 2011 Improvements Project, as well as a revised Terms of Reference and Preface to International Public Sector Accounting Standards. The IPSASB handbook is currently available and can be ordered here.

    The material contained in the handbooks was developed by the IAASB, IESBA, and IPSASB, respectively. The structures and processes that support the operations of these independent standard-setting boards, including publishing the handbooks, are facilitated by IFAC.

    About IFAC
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

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  • IFAC Opens Debate on Public Interest: Issues Policy Position Paper 5, A Definition of the Public Interest

    New York, New York English

    The International Federation of Accountants (IFAC), the global organization for the accountancy profession, today issued Position Paper 5, A Definition of the Public Interest.

    A hallmark of the accountancy profession is its obligation to act in the public interest. But it is not always apparent what this means, and how accountants can determine whether they are meeting this expectation. IFAC, by developing this position paper, is seeking to advance its understanding of this important issue. The paper, which presents a practical definition of the public interest, was developed in the context of IFAC’s mission, to enable IFAC to assess the extent to which its actions and decisions are made in the public interest.

    In light of the challenges presented by prevailing market and economic conditions, policy makers, regulators, standard setters, professional accountants, and others in the financial system are examining their roles, responsibilities, and actions; and therefore it is timely to consider the basis on which these actions are taken, and decisions made.

    “IFAC developed this definition of the public interest to assist us in evaluating whether our actions and decisions are in fact in the public interest,” said IFAC CEO Ian Ball. “Whether we are using it to develop public policy positions, professional standards, or guidance and tools, we believe the definition provides rigor, objectivity, and consistency in assessing the important public interest perspective of our work. It applies not only to evaluating past and current actions and decisions; but also guides our behavior and the manner in which we assess future actions and decisions. We believe that the definition may also be relevant to other organizations and individuals that seek to act in the public interest, and feel the need for increased rigor in evaluating their actions and decisions.”

    The development of the position paper included a public consultation process. Comments and feedback received from a range of stakeholders in the accountancy profession, regulatory community, and academia were considered, and incorporated into the final paper. “While we consulted widely on this policy position paper before issuing it, we continue to invite dialogue on the subject,” continued Ball. “Clearly it is a complex subject, and we hope that this paper is the beginning, rather than the end, of the debate.” 

    IFAC welcomes comments on this paper to: PubInt@ifac.org

    About IFAC
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

     

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  • IFAC Issues New Guidance to Help Organizations Improve Internal Control

    New York, New York English

    The Professional Accountants in Business (PAIB) Committee of the International Federation of Accountants (IFAC) has issued new International Good Practice Guidance, Evaluating and Improving Internal Control in Organizations, highlighting areas where the practical application of existing internal control standards and frameworks often fails in many organizations.

    “Sound internal control practices that are continuously adapted to changing circumstances are critical for organizations,” said Roger Tabor, chair of the PAIB Committee. “Organizations are most successful when they can take advantage of opportunities and defend against threats, both of which are enabled by an appropriate system of internal control.”

    The new guidance will assist professional accountants in business as they work with their organizations to continuously evaluate and improve internal control, and ensure that it is an integrated part of the organization’s systems of governance and risk management. Better integrated internal controls can save the organization time and money while helping to create and preserve value.

    “Organizations need to evaluate and review their internal controls at all levels and within all functions to continue to achieve their objectives,” said Henny Kapteijn, chair of the PAIB Committee’s Risk Management and Internal Control Task Force. “A Professional accountant in business, armed with this guidance, can help lead his or her organization through this process to ensure ongoing, effective internal control.”

    About International Good Practice Guidance
    International Good Practice Guidance (IGPG) issued by the PAIB Committee cover areas of international and strategic importance in which professional accountants in business are likely to engage. In issuing principles-based guidance, IFAC seeks to foster a common and consistent approach to those aspects of the work of professional accountants in business not covered by international standards. IFAC seeks to clearly identify principles that are generally accepted internationally and applicable to organizations of all sizes in commerce, industry, education, and the public and not-for-profit sectors. Previously issued IGPGs are available on the IFAC website, including Preface to IFAC’s International Good Practice Guidance.

    About the PAIB Committee
    The PAIB Committee serves IFAC member bodies and professional accountants worldwide who work in commerce, industry, financial services, education, and the public and the not-for-profit sectors. Its aim is to promote and contribute to the value of professional accountants in business by increasing awareness of the important roles professional accountants play, supporting member bodies in enhancing the competence of their members, and facilitating the communication and sharing of good practices and ideas.

    About IFAC
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

     

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  • IPSASB Publishes Public Sector Combinations Consultation Paper

    New York, New York English

    The International Public Sector Accounting Standards Board (IPSASB) today released for comment the Consultation Paper, Public Sector Combinations. The IPSASB considers guidance on reporting public sector combinations necessary to meet the objectives of financial reporting, which are to provide information that is useful to users of General Purpose Financial Reports (GPFRs) for accountability and decision-making purposes. This project aims to present a principles-based approach to developing guidance for public sector entities on accounting for public sector combinations.

    The Consultation Paper describes different types of public sector combinations and explores possible approaches to recognizing and measuring public sector combinations in GPFRs. It proposes a distinction between acquisitions and amalgamations. The Consultation Paper then considers approaches to combinations of entities and operations that are not under common control and of entities and operations that are under common control.

    "Acquisitions and amalgamations occur regularly in the public sectors around the world. This Consultation Paper is the first step in proposing financial reporting requirements that will ensure that these transactions are reported in a consistent and transparent manner, ensuring that users’ are able to obtain the information needed to evaluate the nature and financial effect of a public sector combination," explained IPSASB Chair Andreas Bergmann.

    How to Comment
    To access the Consultation Paper and the At-a-Glance document, which provides a summary of the Consultation Paper, or to submit a comment letter, please visit the IPSASB website at www.ipsasb.org. Comments on the Consultation Paper are requested by October 31, 2012. The IPSASB encourages IFAC members, associates, and regional organizations to promote the availability of this Consultation Paper to their members and employees.


    About the IPSASB

    The IPSASB develops accounting standards and guidance for use by public sector entities. The structures and processes that support the operations of the IPSASB are facilitated by IFAC. The IPSASB receives support (both financial and in-kind) from the World Bank, the Asian Development Bank, the United Nations and the governments of Canada, China, New Zealand, and Switzerland.

    About IFAC 
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

     

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  • IAASB Indicates Future Direction of Improved Auditor Reporting; Consults on Value, Viability, and Illustrative Report

    New York, New York English

    The International Auditing and Assurance Standards Board (IAASB) today released a key milestone consultation document in its work to enhance, on a global basis, the communicative value of the auditor’s report on financial statements. The IAASB’s Invitation to Comment: Improving the Auditor's Report sets out the indicative direction of the board’s future standard-setting proposals to improve how and what auditors report in accordance with International Standards on Auditing (ISAs).

    The Invitation to Comment (ITC) features a revised auditor’s report that illustrates the application of the IAASB’s suggested improvements. The ITC also provides the IAASB’s rationale for the suggested improvements, together with a discussion of their potential value and impediments, and in what areas feedback is sought. 

    “The global financial crisis has spurred users of audited financial statements to want to know more about individual audits and to gain further insights into the audited entity and its financial statements. While the auditor’s opinion is valued, many perceive that the auditor’s report could be more informative and shine light on key matters based on the auditor’s work. Change, therefore, is essential and the IAASB is strongly committed in the public interest to deliver meaningful improvements to auditor reporting as quickly as possible,” said Prof. Arnold Schilder, IAASB chairman.

    At the heart of the suggested improvements is the need for transparency on matters specific to the audited financial statements and the audit that was performed. A proposed new section in the auditor’s report, “Auditor Commentary,” is envisaged to be the mechanism by which auditors may call attention to matters that are, in the auditor’s judgment, likely to be most important to the users’ understanding of the audited financial statements or the audit. There are also suggested improvements with respect to new statements regarding going concern and other information in documents containing the audited financial statements, the description of the responsibilities of the auditor and key features of the audit itself, and enhancement to the format of the report.

    “The Consultative Advisory Group (CAG), which comprises over 30 member organizations and observers that are key stakeholders of the IAASB, is of the view that this is a very important project,” said Linda de Beer, IAASB CAG chairman. “All CAG member organizations, but in particular user groups and regulators, are of the view that the auditor’s report should point the reader to key aspects important for an understanding of the entity and its financial statements. Mandatory auditor commentary will go a long way to address this need of shareholders and others. The CAG responded very positively at its meeting in March 2012 to the aspects that the IAASB is addressing in the ITC.”

    Noted James Gunn, IAASB technical director, “The IAASB has heard – and indeed embraces – the call from stakeholders to re-examine and, to an extent re-invent, the auditor’s report. There is still much work to be done, and the IAASB will continue its deliberations in 2012 and 2013. However, it is critical that the IAASB hear from a wide range of stakeholders at this stage regarding the suggested improvements and whether they will achieve the value that users seek in order for the board’s future standard-setting proposals to develop in a way that will best serve the public interest.”

    The ITC includes planned dates for IAASB roundtables in the North American (September 10), European (September 14), and Asia Pacific (October 8) regions. The IAASB intends to finalize plans for these roundtables in the coming weeks, and will post them on its Auditor Reporting page.

    How to Comment
    The IAASB invites all stakeholders to respond to this ITC. To access the ITC and submit a comment, visit the IAASB’s website. Comments on the ITC are requested by October 8, 2012.

    About the IAASB

    The IAASB develops auditing and assurance standards and guidance for use by all professional accountants under a shared standard-setting process involving the Public Interest Oversight Board, which oversees the activities of the IAASB, and the IAASB Consultative Advisory Group, which provides public interest input into the development of the standards and guidance. The structures and processes that support the operations of the IAASB are facilitated by IFAC.

    About IFAC

    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

     

     

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  • Jörgen Holmquist Appointed First Independent Chair of the International Ethics Standards Board for Accountants

    New York, New York English

    The International Federation of Accountants today announced that Jörgen Holmquist has been appointed as the first independent chair of the International Ethics Standards Board for Accountants (IESBA), beginning September 2012 for a three-year term. The appointment has been approved by the Public Interest Oversight Board*.

    “Jörgen brings a wealth of experience to the position of independent chair of the IESBA,” said IFAC President Göran Tidström. “In his past roles, as well as in his current position as a public member of the IESBA, he has shown strong leadership skills, technical competence, and a commitment to the IESBA and its mission to protect the public interest. I am confident that, under his leadership, the IESBA will continue to make a highly effective contribution to ethics standard setting as well as, importantly, adoption and implementation. I would like also to acknowledge the exemplary contribution and commitment Ken Dakdduk brought to the role, and to his position on the board, over the past seven years.” 

    Mr. Holmquist has been a public member of the IESBA since 2011. He served as Director General, DG Internal Market and Services, European Commission from 2007 to 2010, where he was responsible for developing the European Union (EU) regulatory response to the financial crisis, including legislation and policy concerning accounting and auditing. Before joining the European Commission in 1997, he served in the Swedish Ministry of Finance for twenty years. Mr. Holmquist holds a degree in Economics and Mathematics from the University of Stockholm, Sweden and is a Fellow of the Weatherhead Center for International Affairs at Harvard University.

    The appointment of an independent chair for the IESBA was recommended by the Monitoring Group in its “Review of the IFAC Reforms — Final Report,” which was issued in 2010.

    In his role as chair, Jörgen Holmquist will provide leadership to the IESBA. A key function of the chair is to enable, encourage, and promote a deeper understanding by stakeholders and the public of the strategies and activities of the IESBA. The chair also leads the strategic direction of the IESBA, working closely with IESBA staff, and facilitates the deliberative and consultative processes that underpin the authority of the IESBA and the legitimacy of its standards and activities. In addition, the chair is involved in developing and maintaining effective relationships with national standard setters, regulators, and other key stakeholders.

    “Convergence to a single set of high-quality ethical standards will contribute to efficient, sustainable, and vibrant capital markets and is in the public interest,” Jörgen Holmquist commented. "I look forward to advancing the IESBA’s current initiatives, as well as the recently announced additional workstreams, enhancing relationships with national standard setters, regulators, governments, and the public and promoting adoption and implementation of the Code."

    *Notes to Editors
    The international Public Interest Oversight Board (PIOB) was established in February 2005 to ensure that international auditing and assurance, ethics, and education standards for the accountancy profession are set in a transparent manner that reflects the public interest. The objective of the PIOB is to increase confidence of investors and others that such activities, including the setting of standards by the IESBA, are properly responsive to the public interest. PIOB members are nominated by international institutions and regulatory bodies.


    About the IESBA
    The International Ethics Standards Board for Accountants (IESBA) is an independent standard-setting board that develops and issues, in the public interest, high-quality ethical standards and other pronouncements for professional accountants worldwide. Through its activities, the IESBA develops the Code of Ethics for Professional Accountants, which establishes ethical requirements for professional accountants. The structures and processes that support the operations of the IESBA are facilitated by IFAC. Please visit www.ifac.org/ethics for more information.

     

    About IFAC
    IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

     

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  • IFAC Announces Appointment of Fayezul Choudhury as New Chief Executive Officer

    New York, New York English

    The International Federation of Accountants (IFAC), the global organization for the accountancy profession with members and associates in 127 countries, is pleased to announce that Fayezul (Fayez) Choudhury has been selected as the new CEO of IFAC. He succeeds current CEO Ian Ball, whose contract is set to expire in February 2013.

    Mr. Choudhury was previously with the World Bank, where his last two assignments were as Vice President, Corporate Finance and Risk Management; and Controller and Vice President, Strategic Planning and Resource Management. In this latter role he was the World Bank's spokesperson on global accounting and auditing issues. Mr. Choudhury started his career in 1974 with Price Waterhouse in London, initially in public accounting and later management consulting. During his career with Price Waterhouse, he spent three years in Nigeria, developing the consulting practice in that region.        

    Mr. Choudhury has served on a number of high level representative bodies He was a member of the Public Interest Oversight Board (PIOB) from its formation in 2005 until 2010. The PIOB was established to ensure that international auditing and assurance, ethics, and education standards for the accountancy profession are set in a transparent manner that reflects the public interest. Mr. Choudhury also chaired the Global Steering Committee of the International Forum for Accountancy Development and was a member of the Standards Advisory Council of the International Accounting Standards Board. He served as a member of the Iraq Advisory and Monitoring Board established by the Security Council of the United Nations.

    Mr. Choudhury has an MA (Hons) in Engineering Science and Economics from the University of Oxford. He is also a Fellow of the Institute of Chartered Accountants of England and Wales.

    IFAC President Göran Tidström notes that “Fayez has more than 36 years of experience in the accountancy profession. He brings a strong understanding of the role of accounting in organizations and knowledge of the issues surrounding the global profession. He was instrumental in the discussions that led to the creation of the current private/public sector governance arrangements for international standard-setting and has extensive knowledge of IFAC through his work in the PIOB. We are very happy to welcome Fayez to this new role.”

    Mr. Choudhury stated “I am honored to have been selected for this position. I firmly believe that accountancy is one of the core professions that anchor the functioning of modern societies and, as such, the role of IFAC is critically important.”

    Mr. Choudhury was recruited after an extensive global search led by an executive search firm. 

    About IFAC
    IFAC (www.ifac.org) is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

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